What changed
RBI has forwarded a new consolidated list of individuals and entities linked to Al-Qaida, as updated by the UN Security Council's 1267 Committee via a Government of India note dated September 15, 2011. This updates the previous list referenced in the September 19, 2011 circular. Banks must now use this updated list for all customer screening.
What it means for you
Urban Co-operative Banks must immediately update their internal sanctions screening systems with the latest UN list to avoid onboarding or retaining prohibited entities. Non-compliance with the UAPA Order and RBI's freezing instructions could lead to regulatory action. This reinforces the ongoing obligation to monitor both new and existing accounts against evolving terrorist financing risks.
What you must do
- Update your internal consolidated list of UN 1267 Committee-designated individuals/entities with the latest version received from RBI.
- Screen all new account applications against the updated list before opening accounts.
- Conduct a fresh scan of all existing accounts to identify any matches with the updated list.
- Follow the freezing procedures detailed in paragraph 6 of RBI circular UBD.CO.BPD.PCB.Cir.No.21/12.05.001/2009-10 dated November 16, 2009 for any matched accounts.
- Ensure the Compliance Officer/Principal Officer acknowledges receipt of this circular to the respective RBI Regional Office.
Who it affects
All Primary (Urban) Co-operative Banks, Compliance Officers and Principal Officers of Urban Co-operative Banks, Branch managers handling account opening and monitoring
Where can I find the full consolidated list of sanctioned individuals/entities?
The complete list is available on the UN website at http://www.un.org/sc/committees/1267/aq_sanctions_list.shtml. RBI has also enclosed a copy of the UN note with this circular.
What action should I take if I find an existing account matching the updated list?
You must immediately freeze the funds, financial assets, or economic resources held in that account, following the detailed procedures in paragraph 6 of RBI's November 16, 2009 circular (UBD.CO.BPD.PCB.Cir.No.21/12.05.001/2009-10).
Is this circular applicable only to Urban Co-operative Banks?
Yes, this specific circular is addressed to all Primary (Urban) Co-operative Banks. Other bank categories may have separate instructions.